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Moore v. U.S., No. 13-2353, 2014 WL 2575765 (D. Md. June 6, 2014) (Quarles, Jr., J.)


Moore v. U.S., No. 13-2353, 2014 WL 2575765 (D. Md. June 6, 2014) (Quarles, Jr., J.)

Re: Request for plaintiff's ATF personnel file

Disposition: Granting defendant's motion for summary judgment

  • Procedural Requirements, Searching for Records:  The court holds that "[a]lthough [plaintiff] believes that additional documents are responsive to his request, agencies are not obligated to look beyond the 'four corners' of a FOIA request 'when formulating their searches, nor [are] they required to chase rabbit trails that may appear in documents uncovered during their search.'"  The court notes that "[plaintiff's] FOIA request, on its face, seeks only a copy of his 'complete' personnel file 'including' all the documents within it.  The court finds that "ATF reasonably interpreted [plaintiff's] request to mean that he wanted a copy of his [official personnel file], which it produced in full."  The court holds that "[i]f [plaintiff] wishes ATF to produce additional documents that were not in his [official personnel file], he should submit a second FOIA request."
  • Attorney Fees:  The court relates that "[i]n addition to a Court order requiring ATF to respond to his FOIA request, [plaintiff's] complaint requests money damages and costs."  The court holds that "[m]oney damages are not available under FOIA" and "[t]hus, ATF will be granted summary judgment on this claim."  However, the court notes that "[plaintiff] may move for an award of costs within 21 days of the date of the Order accompanying this opinion."  The Court states that it "will reserve judgment on whether he is entitled to costs until the issue has been fully briefed."
Court Decision Topic(s)
District Court opinions
Attorney Fees
Procedural Requirements, Searching for Responsive Records
Updated February 2, 2022